Keys to Compliance

Screening

  The easiest way to determine that an organization is not doing business with a denied, debarred, or embargoed entity is to obtain a subscription to an online screening tool that will review names, countries, and companies for you to make sure they are not on the "bad guy" lists.

If you are unable to obtain a subscription to one of those online services, your organization will be required to review the lists by hand at each stage of the transaction.

This means that a potential customer may be screened multiple times by multiple people in your organization. At a minimum your organization should screen every new business contact at the time of the identification of a business opportunity. Because the U.S. Government lists change daily (usually with new parties being added, although occasionally with someone being removed), your organization will need to screen at the time you make the bid/no-bid decision internally. And again when the proposal is ready to be sent out, before contract acceptance and finally before delivery. Because the lists change so frequently, and because the U.S. Government holds each company to the standard of knowing who you are doing business with, you will be required to make sure that your potential customer is alright to do business with each step of your business plan.